John G. and Janice E. Parker - Page 7




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          by the taxpayer in carrying on the activity; (4) the expectation            
          by the taxpayer that the assets used in the activity may                    
          appreciate in value; (5) the success of the taxpayer in carrying            
          on other similar or dissimilar activities; (6) the taxpayer’s               
          history of income or losses with respect to the activity; (7) the           
          amount of occasional profits earned by the taxpayer, if any;                
          (8) the financial status of the taxpayer; and (9) elements of               
          recreation or personal pleasure in the taxpayer’s carrying on the           
          activity.                                                                   
               Although no single factor is conclusive, a record of                   
          substantial losses over many years and the unlikelihood of                  
          achieving a profit are important factors bearing on whether the             
          taxpayer had a profit objective in carrying on the activity.                
          Golanty v. Commissioner, supra at 426; sec. 1.183-2(b)(6), Income           
          Tax Regs.  Generally, the profit-objective test looks for a                 
          profit on the entire activity, including profits to recoup losses           
          from prior years.  Golanty v. Commissioner, supra at 427 (citing            
          Bessenyey v. Commissioner, 45 T.C. 261, 274 (1965), affd.                   
          379 F.2d 252 (2d Cir. 1967)).                                               
               Substantial income from sources other than the activity,               
          particularly where the activity generates large losses that                 
          result in substantial tax benefits, may indicate that the                   
          activity is not engaged in for profit, especially if the activity           








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